Privacy Policy

Introduction

Computer Wholesalers, Inc. (the “Company,” “us,” “we,” or “our,” as the context may require) operates and provides the website gocwi.com, (the “Site“), through which we purchase and sell computers, related equipment and perform certain related services (collectively the “Services“).

We respect the privacy of the users of the Site and Services (“you” or “your,” as the context may require) and are committed to protecting it through compliance with this Privacy Policy (this “Policy“). This Policy describes:

• The types of information we may collect or that you may provide when you download, install, register with, access, or use the Site.
• The types of information we may collect via or that you may provide when you visit, access, or use the Site and Services.
• Our practices for collecting, using, maintaining, protecting, disclosing and processing that information.

The Interactions this Policy Covers

This Policy applies to personal information (as defined below) we collect in or via the Services, and in email, text, telephone, and other electronic communications sent through or in connection with the Services and the Site.

Except as otherwise provided in this Policy, “personal information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. “Personal information” does not include information which is generally not considered “personal information” or “personal data” under applicable law, such as information which is publicly available or subject to a special data privacy regime, such as protected health information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

This Policy DOES NOT apply to information that:

• Except with respect to Section 11 or as required by applicable law, we collect offline.
• Is collected through any applications or websites other than the Services, including third-party websites you may access through the Site.
• You provide to or is collected by any third party (see Third Party Information collection below).

Other websites, applications, and other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

If you do not agree with our policies, practices, or terms and conditions contained in this Policy or any other terms and conditions stated on the Site, please do not download, register with, sell or purchase product from or otherwise interact with, and do not visit, use or access the Site.

This Policy may change from time to time (see Section 13, Changes to this Policy). Your continued use of the Services after we revise this Policy means you accept those changes.

Children’s Privacy

The Services and Site are not directed to nor intended for use by children under 16 years of age. We do not knowingly collect personal information from children under 16. No one under age 16 may use the Sites or Services. If you are under age 16 years of age, do not use or provide any personal information to, on, or through the Services. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us by any of the methods listed in the Contact Information section below.

Information We Collect

We collect several types of information from and about you as a result of your use of or registration with the Site, and as a result of your communication with us. This information may include:

• Personal information, such as:
  • Name
  • Postal address
  • Email address
  • Telephone number
  • Credit card number
  • Position
  • Account password
  • Any other personal information, business information or product information that you upload or share to or on the Services, or which you otherwise provide directly to us.
• Information about your purchases and sales;
• Information that is about you, your business, and your products but individually does not identify you, such as information which has been de-identified or aggregated in a manner where it can no longer be used to identify you;
• Information about your internet connection, the equipment you use to access the Services, and usage details; and
• Any other form or category of information, including personal information, which you publicly disclose or share on the Services, or disclose to or share with us in any manner.

How We Collect Personal Information

We collect information, including personal information, from and about you:

• Directly from you when you provide it to us. For example, we collect your information if you buy or sell computer and related equipment on the Site.
• Automatically when you use or access the Site and Services. We use tracking tools like browser cookies and beacons.
• We may obtain information about you from third parties.

1. 1. Information You Provide to Us

The information, including personal information, we collect when you download, register with, or use or access the Site or Services, may include:

• Information that you provide by filling in forms in the Services. This includes information provided at the time of registering to use the Services, posting material on or to the Services, and requesting further services. We may also ask you for information when you report a problem with the Services, request support or otherwise communicate with us via the Site or regarding the Services.
• Records and copies of your correspondence (including email addresses and phone numbers) if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through the Services and of the fulfillment of your orders. You may be required to provide financial information before purchasing or selling computer and related equipment over the Site or by utilizing our Services.
• Your search queries on the Site.
• Make and model of computers and other equipment purchased or sold via the Site.
• Location.

Automatic Information Collection

When you download, access, or use Site or Services, we may use automatic data collection technologies to collect certain information, including:

• Usage Details. When you access and use the Site and Services, we may automatically collect certain details of your access to and use of the Site and Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Services.
• Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
• Stored Information and Files. The Site also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

The information we collect automatically is only statistical data and does not generally include personal information, but we may maintain it or may associate it with other personal or business information we collect in other ways or which we receive from third parties.

If you do not want us to collect this information do not use the Site or Services. You may opt out at any time by contacting us via email.

We also may use these technologies to collect information about your activities over time and across third-party websites or other online services (behavioral tracking).

The technologies we use for automatic information collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone, tablet, computer, or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone, tablet, computer, or other device. However, if you select these setting you may be unable to access certain parts of the Services.

Analytics. We utilize third party companies and analytics to help us market, sell, and provide information about our products and services; and we provide your personal information to these third-party companies to assist us in conducting business with you. We may use web analytics tools provided by service providers, including but not limited to, Google Analytics and Google AdSense, which is a third-party service that transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We may use reports provided by Google Analytics or other similar service providers, to help us understand traffic on the Services, and web page usage. For more information concerning Google Analytics and how it collects and processes data please see “How Google Uses Data When You Use Our Partners Web Sites or Apps” located at www.google.com/policies/privacy/partners. We may use the information provided by these tools to improve our services and our online advertisements. These tools place session and persistent cookies in your browser to identify you as a unique user the next time you visit, access, or use the Services. Each cookie cannot be used by anyone other than the service provider (e.g. Google Analytics).

Third-Party Information Collection

When you use the Services, or their content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.
• Analytics companies.
• Your mobile device manufacturer.
• Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Privacy Choices section below.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

• Provide you with the Services, their contents, and any other information, products or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Give you notices about your account.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you of changes to any products or services we offer or provide though the Site or Services.
• Notify you to participate in upcoming events.
• To set up a call or meeting with you.
• Help you identify dealer locations.
• Fulfill any other item we may describe when you provide the information.
• For any other purpose with your consent.

The usage information we collect helps us to improve the Site and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize the Services according to your individual interests.
• Speed up your searches.
• Recognize you when you use the Site or Services.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the order form/registration form)/adjust your user preferences in your account profile. For more information, see Your Privacy Choices section below.

We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users and information that does not identify any individual without restriction.

In addition, we may disclose personal information that we collect, or you provide:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who use your information only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
• To third parties to market their products or services to you if you have consented to/not opted out of these disclosures.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.

Your Privacy Choices

We strive to provide you with and inform you of choices regarding your information, including personal information. This Section 8 describes mechanisms for you to control certain uses and disclosures of your information.

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services and the Site may then be inaccessible or not function properly.
• Location Information. You can choose whether to allow the Services to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Services may become inaccessible or not function properly.
• Promotion by the Company. If you do not want us to use your email address to promote our own or third parties’ products or services, you can opt-out by unsubscribing from any emails you received from us or a third party. You can also always opt-out by adjusting your user preferences in your account profile by sending an email to us or unsubscribing from any email you receive from us.
• Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending an email to us or unsubscribing from any email you receive from us.
• Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by sending an email to us or unsubscribing from any email you receive from us.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

For information on accessing and/or correcting your personal information which we hold, please see Accessing and Correcting Your Personal Information.

If you are in the European Economic Area, you may have additional rights and choices regarding your personal information. Please see Notice for Individuals Located in the European Economic Area for additional information on your rights regarding your information.

If you are a resident of the state of California (as defined in Cal. Civ. Code § 1798.140(g)), you may have additional rights and choices regarding your personal information. Please see Notice for California Residents for more information.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the Site and visiting your account profile page.

You may also send us an email at the email address stated at the end of this policy to request access to, correct, or delete any personal information that you have provided to us. Please note if we comply with your request to delete your personal information, we will, by necessity, also delete your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Scope

This Section 10 applies exclusively to visitors and users of Services who are located in the European Union (EU) and/or European Economic Area (EEA) (“Data Subjects“).

Rights of Data Subjects

If you are a Data Subject, you have the following rights:

• The right to request copies of your personal information. If you require more than one copy, we may charge you a reasonable fee.
• The right to request that we correct any personal information that you believe is inaccurate, or complete any personal information which you believe is incomplete.
• The right to request that we erase your personal information, under certain circumstances.
• The right to request that we restrict the processing of your personal information, under certain circumstances.
• The right to object to our processing of your personal information, under certain circumstances.
• The right to request we transfer data that we have collected to you or directly to another organization, under certain circumstances.
• The right to withdraw your consent, explicit or otherwise, at any time. If we rely on your consent as the legal basis for our processing of your personal information, we will refrain from processing your data.

For the purposes of European data protection laws, we are the data controller, i.e. the company responsible for controlling the processing of personal information covered by this Policy.

If you are a Data Subject and would like to exercise any of these rights, please contact us as provided in Contact Information.

Transfer of Personal Information

The Services are operated and managed on servers located and operated in the United States. Any information collected through the Services as described in this Policy is stored in the United States. The United States is not recognized as having adequate safeguards by the European Economic Area. If you are located outside of the United States, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the United States.

Notice for California Residents

Scope; Definitions

This Section 11 applies exclusively to visitors and users of the Site and Services who are residents of the state of California (as defined in Cal. Civ. Code § 1798.140(g)) (“Consumers“). As used in this Section 11, the term “you” and “your” shall only refer to a Consumer. For purposes of this Section 11, “personal information” has the meaning set forth in Cal. Civil Code § 1798.140(o).

If you are a Consumer, the California Consumer Privacy Act (“CCPA“) provides you with certain rights regarding your personal information. This Section 11 includes additional notices with respect to and describes those rights and provides you with additional information regarding our practices regarding the collection, use, disclosure, and sale of personal information.

This Section 11 supplements the information contained elsewhere in this Policy with respect to Consumers and notifies Consumers of certain rights they have under the CCPA.

Categories of Personal Information Collected

We may collect, and in the last twelve (12) months have collected, the following categories of personal information from Consumers:

Categories of Sources of Personal Information

We may collect your personal information from the categories of sources of personal information identified in How We Collect Personal Information. For the sake of clarity, these categories may include: you directly, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks and data brokers.

Use of Personal Information

We may collect, use, maintain, disclose, and otherwise process your personal information for the business and/or commercial purposes identified in How We Use Your Personal Information.

Disclosure of Personal Information

We may disclose your personal information to a third party for a business purpose.

We share your personal information with the following categories of third parties:

• Payment processors
• Product and service dealers
• Internet cookie data recipients, like Google Analytics.
• Shippers
• To companies through which we sell products like eBay.
• Mail and overnight carriers.

1. 1. 1. I.  Disclosures of Personal Information for a Business Purpose

We may disclose, and in the preceding twelve (12) months have disclosed, the personal and business information you have disclosed to as further identified in this Policy for a business purpose as set forth in this Policy.

Rights and Choices under the CCPA

The CCPA provides Consumers with certain rights regarding their personal information. This Section 11.F describes these rights and explains how Consumers may exercise them.

1. 1. 1. I.  Right to Opt-Out of the Sale of Personal Information

The Company does not sell your personal information.

1. 1. 1. II.  Right to Know; Data Access and Data Portability Requests

You have the right to request that we disclose certain information (the “Right to Know“) to you about our collection, use, disclosure, of your personal information over the past twelve (12) months (a “Request to Know“).

Once we receive and verify your Request to Know (see Exercising Access, Data Portability and Deletion Rights), we will disclose to you each of the following items which you include in your Request to Know:

• The categories of personal information we have collected about you;
• The categories of sources for the personal information we have collected about you;
• Our business or commercial purpose for collecting or selling that personal information;
• The categories of third parties with whom we have shared that personal information;
• The specific pieces of personal information we have collected about you; (if delivered by mail, a “Data Access Request,” and, if delivered to you electronically in a portable format, a “Data Portability Request“);
• If we have sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

To submit a Request to Know, Data Access Request, or Data Portability Request see Exercising Access, Data Portability and Deletion Rights.

1. 1. 1. III.  Right to Request Deletion

You have the right to request that we delete any of your personal information that we have collected from you or have maintained or retained, subject to certain exceptions (a “Request to Delete“). Under certain exceptions, we may deny your right to Request to Delete. We may deny your Request to Delete if the information is necessary for us or our service providers to:

• Complete the transaction for which the personal information was collected, or to provide a good or service that you have requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Identify security breaches, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another Consumer to exercise their free speech rights, or exercise another right provided for by law.
• Enable solely internal uses that are reasonably aligned with Consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To submit a Request to Delete, see Exercising Access, Data Portability and Deletion Rights.

1. 1. 1. IV.  Right to Non-Discrimination

You have the right to not receive discriminatory treatment for your exercise of privacy rights under the CCPA, by, for example, being denied goods or services or being charged different prices for goods or services because of your exercise of CCPA rights.

1. 1. 1. V.  Authorized Agent

You may authorize another person (an “Authorized Agent”) to exercise any of your rights under the CCPA and this Section 11. To designate an Authorized Agent to make a request with us, (i) provide the authorized agent signed permission to submit a request under this Section 11 with us, and (ii) confirm with us that you provided the Authorize Agent permission to submit the request by submitting such signed permission to us by email at info@cwi.com. Please note that you may be required to verify your identity before your confirmation of permission for the Authorized Agent is effective under this Section 11.

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights described in Rights and Choices under the CCPA, please submit a verifiable consumer request to us by either:

• Calling us at 877-216-2177
• Emailing us at CustomerService@gocwi.com
• Only you or your Authorized Agent (as defined below) may make a verifiable consumer request related to your personal information.  You may also make a verifiable consumer request on behalf of your minor child who is a Consumer.

You may only make a Request to Know, Data Access Request, or Data Portability Request twice within a twelve (12) month period.  Your Request to Know, Data Access Request, or Data Portability Request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person, which may include:
  • Information which we already maintain; or
  • If we cannot verify your identity based on information already maintained by us, such information that we or our representatives request from you.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. If we cannot verify your request within 45 days from the date that we receive your request, we may deny your request.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising your right to opt-out of the sale of your personal information, see Right to Opt-Out of the Sale of Personal Information.

Other California Privacy Rights

California’s “Shine the Light” law (Cal. Civil Code § 1798.83) permits Consumers to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not currently disclose personal information to third parties for their direct marketing purposes.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas on the Site or otherwise. The information you share in public areas may be viewed others.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted via the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to this Policy

We may update this Policy from time to time. If we make material changes, we will post the updated Policy on this page with a notice showing the date that this Policy was last updated. Your continued use of the Site and/or Services indicates your acceptance of the revised policy.

The dates this Policy was last reviewed and last modified is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, you may contact us at:

• Calling us at 877-216-2177
• Emailing us at CustomerService@gocwi.com
• If you are a Data Subject and feel we have not resolved a privacy concern related to personal information process or transferred by the Company, you have the right to submit a complaint to a supervisory authority.